https://www.taxtmi.com/caselaws?id=220863 For exemption under Section 10(23C), an institution must exist solely for educational purposes and not for profit; the controlling test is whether it is carried on with a profit motive, not whether it has generated incidental surplus. Applying the predominant object test, receipts from fees and grants, occasional surpluses used to improve educational infrastructure, and additions to fixed assets did not show a profit-making purpose. Surplus in some years did not displace the institution's dominant educational character. The finding that it existed for profit was therefore erroneous, and the denial of exemption on that basis could not stand. en-us Thu, 31 Jan 2013 00:00:00 +0530 Fri, 28 Jun 2013 14:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=220863 For exemption under Section 10(23C), an institution must exist solely for educational purposes and not for profit; the controlling test is whether it is carried on with a profit motive, not whether it has generated incidental surplus. Applying the predominant object test, receipts from fees and grants, occasional surpluses used to improve educational infrastructure, and additions to fixed assets did not show a profit-making purpose. Surplus in some years did not displace the institution's dominant educational character. The finding that it existed for profit was therefore erroneous, and the denial of exemption on that basis could not stand. Case-Laws Income Tax Thu, 31 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=220863